Tax compliance practice: The final BMF letter on the income tax treatment of fund establishment costs dated January 19, 2026

The income tax treatment of fund establishment costs in accordance with Section 6e of the German Income Tax Act (EStG) has been the subject of debate for years. The BMF letter dated January 19, 2026 now provides a final administrative opinion on the interpretation of this provision.

In this article, Dmytro Shyshkin explains the key points of the letter from the perspective of tax compliance practice in the private equity sector.